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ENCINAS VS NATIONAL BOOKSTORE

FACTS:

This case involves a parcel of land titled to two different persons. Encinas claimed that the land is hers and
that the original title in her name was among those burned in the Registry of Deeds in Quezon City in 1988.
The Land Registration Authority upon determining that the alleged title does not overlap with other
properties ordered the issuance of a reconstituted title to Encinas. When Encinas offered to sell the property
to respondent it was discovered that her title covers the same lot already owned by National Bookstore.
Meanwhile, the LRA after discovering its error of issuing a reconstituted title over the same lot, retracted its
decision set aside its earlier order or reconstitution. Encinas filed a case of quieting of title before the
Regional Trial Court. The Court decided in favor of National Bookstore but upon the filing a motion for
reconsideration it reversed its own decision and ordered the cancellation of the latter’s title since Encinas
is the supposed real owner of the property. National appealed to the Court of Appeals which reversed the
RTC decision. Encinas then appealed the CA decision to the Supreme Court.

ISSUE: WON Encinas is the owner of the property.

Encinas is not the True Owner of the Property. In upholding the ownership of the National Bookstore over
the subject property, the SC agreed that National sufficiently proved its ownership of the land. Encinas
heavily relied on the probative value of her reconstituted title and did not present any evidence as to how
she came to own the land considering the fact that she is a resident of the United States. Also, the
documents she presented such as tax declarations pertain to a different lot and not the subject property.The
High Tribunal declared that National Bookstore “…was able to overcome the burden of proof and prove by
preponderant evidence that it has a superior right and title to the subject property. In contrast, petitioners
as defendants seem to rely only on the alleged weakness of respondents evidence, without asserting any
proof other than her reconstituted title to the subject property.” (G.R. No. 162704, November 19, 2004) The
SC also added that: In civil cases, the party having the burden of proof must establish his case by a
preponderance of evidence. Preponderance of evidence is the weight, credit, and value of the aggregate
evidence on either side and is usually considered to be synonymous with the term greater weight of the
evidence or greater weight of the credible evidence. Preponderance of evidence is a phrase which, in the
last analysis, means probability of the truth. It is evidence which is more convincing to the court as worthy
of belief than that which is offered in opposition thereto. In other words, the Court found the claim of National
more believable and is most probably the true owner as against the claim of Encinas. With that, the SC
upheld the decision of the CA.

LANDANO VS NERI

Facts:
This case originated from a Complaint filed by petitioner Luciano Ladano (Ladano)
before the DARAB Provincial Adjudicator against respondents Felino Neri, Edwin
Soto, Adan Espanola and Ernesto Blanco. Ladano alleged that on May
7, 2003, the respondents forcibly entered the two-hectare land, located in Manalite
I, Barangay Sta. Cruz, Antipolo City, which he and his family have been peaceably occupying and
cultivating since 1970. The said respondents informed him that the property belongs to Neri and that he
should vacate the same immediately. Not too long afterwards, the respondents fenced the property and
destroyed some of the trees and kawayan planted thereon. Ladano prayed that he
be declared the rightful “occupant/tiller” of the property, with the right to security of tenure thereon.
Issue: WON petitioner is a tenant in a tenancy relationship entitled to reliefs prayed for.
Held: No. A tenancy relationship arises between a landholder and a tenant once they agree, expressly or
impliedly, to undertake jointly the cultivation of a land belonging to the landholder, as a
result of which relationship the tenant acquires the right to continue working on and cultivating
the land.” For a tenancy relationship, express or implied, to exist, the following requisites must
be present:
(1) the parties must be landowner and tenant or agricultural lessee;
(2) the subject matter is agricultural land;
(3) there is consent by the landowner;
(4) the purpose is agricultural production;
(5) there is personal cultivation by the tenant; and
(6) there is sharing of harvests between the landowner and the tenant.
Independent and concrete evidence of the foregoing elements must be presented by the party
asserting the existence of such a relationship. They cannot be arrived at by mere
conjectures or by presumptions. “Unless a person has established his
status as a de jure tenant, he is not entitled to security of tenure [nor is he] covered by the
Land Reform Program of the Government under existing tenancy laws.
The DARAB failed to consider that one’s occupancy and cultivation of an agricultural land, no matter
how long, will not ipso facto make him a de jure tenant. It should not have
considered such occupation as a basis for assuming the landowner’s consent,
especially when the occupant himself never alleged that he obtained the
landowner’s consent. Petitioner did not even allege in his Complaint that he is a tenant of
the landowner. Neither did he allege that he shared his harvests with the landowner. Without
such factual assertions from Ladano, the DARAB arrived at
a conclusion that is utterly bereft of factual bases. Petitioner is not a tenant on the
land and is not entitled to security of tenure nor to disturbance compensation. His
Complaint was properly dismissed for lack of merit.
LAND BANK OF THE Philippines. SEVERINO LISTANA, SR.,

FACTS:

Private respondent Listana voluntarily offered to sell his land of 246.0561 ha. in Sorsogon to the
government, through the Department of Agrarian Reform (DAR) under the Comprehensive Agrarian
Reform Program (CARP). DAR valued the property at P5,871,689.03 but Listana refused to sell at that
price, so the Department of Agrarian Reform Adjudication Board (DARAB), in an administrative
proceeding determined the just compensation of the land at P10,956,963.25 and ordered the Land Bank
of the Philippines to pay the same to Listana. A writ of execution was issued by PARAD to that effect but
it was apparently not complied with by LBP so a Motion for Contempt was filed by Listana with the
PARAD against petitioner LBP. PARAD granted the Motion for Contempt and cited for indirect contempt
and ordered the arrest of ALEX A. LORAYES, the Manager of LBP. LBP obtained a preliminary injunction
from the Regional Trial Court of Sorsogon enjoining DARAB from enforcing the arrest order against
Lorayes. Listana filed a special civil action for certiorari with the Court of Appeals. CA nullified the order of
the RTC. Consequently, petitioner LBP filed a petition for review with the Supreme Court.

Issue: Whether the order for the arrest of petitioner's manager, Mr. Alex Lorayes by the PARAD, was
valid.

Held:

The arrest order issued by PARAD against Lorayes was not valid because the contempt proceedings
initiated through an unverified "Motion for Contempt" filed by the respondent with the PARAD were
themselves invalid. Said proceedings were invalid for the following reasons:

The Rules of Court clearly require the filing of a verified petition with the Regional Trial Court, which was
not complied with in this case. The charge was not initiated by the PARAD motu proprio; rather, it was by
a motion filed by respondent.

Neither the PARAD nor the DARAB have jurisdiction to decide the contempt charge filed by the
respondent. The issuance of a warrant of arrest was beyond the power of the PARAD and the DARAB.
Consequently, all the proceedings that stemmed from respondent, "Motion for Contempt," specifically the
Orders of the PARAD dated August 20, 2000 and January 3, 2001 for the arrest of Alex A. Lorayes, are
null and void.

Robosa vs. NLRC

FACTS:

The NLRC issued a TRO and directed CTMI, De Luzuriaga and other company executives to cease and
desist from dismissing any member of the union and from implementing memorandum terminating the ser
vices of the sales drivers, and to immediately reinstate them if the dismissals have been effected.

Allegedly, the respondents did not comply with the NLRC’s resolution. They instead moved to dissolve th
e TRO and opposed the union’s petition for preliminary injunction. Then, the NLRC upgraded the TRO to
a writ of preliminary injunction.The respondents moved for reconsideration. The union opposed the motio
n and urgently moved to cite the responsible CTMI officers in contempt of court.

Meanwhile, the NLRC heard the contempt charge and issued a resolution dismissing the charge. It ordere
d the labor arbiter to proceed hearing the main case on the merits.

ISSUE:

Whether or not the NLRC has contempt powers.

HELD:

Yes. Under Article 218 the Labor Code, the NLRC (and the labor arbiters) may hold any offending party in
contempt, directly or indirectly, and impose appropriate penalties in accordance with law. The penalty for
direct contempt consists of either imprisonment or fine, the degree or amount depends on whether the co
ntempt is against the Commission or the labor arbiter. The Labor Code, however, requires the labor arbite
r or the Commission to deal with indirect contempt in the manner prescribed under Rule 71 of the Rules o
f Court. Rule 71 of the Rules of Court does not require the labor arbiter or the NLRC to initiate indirect con
tempt proceedings before the trial court. This mode is to be observed only when there is no law granting t
hem contempt powers. As is clear under Article 218(d) of the Labor Code, the labor arbiter or the Commi
ssion is empowered or has jurisdiction to hold the offending party or parties in direct or indirect contempt.
Robosa, et al., therefore, have not improperly brought the indirect contempt charges against the responde
nts before the NLRC.

ROSARIO TEXTILE MILLS INC. vs. CA

FACTS:

On 1 August 1984, RMC Garments, Inc. (“RMC”) leased from Peter Pan Corporation (“Peter Pan”) its
properties (“Leased Premises”) located on Ortigas, Metro Manila where RMC, a garments manufacturing
company, installed machinery on the Leased Premises and brought in furniture, office equipment and
supplies.
Two years thereafter, Rosario Textile Mills Corp. (“Rosario Textile”) advised RMC in a letter that it had
acquired the Leased Premises, including the chattels found inside, from GBC Corporation (“GBC”)
through a Deed of Assignment of Rights and Interests and demanded RMC to vacate the Leased
Premises within 10 days. Rosario Textile proceeded to exercise its “right of self help.” Representatives of
Rosario Textile entered the Leased Premises; cut off RMC’s power supply and communication lines;

barricaded the road leading to the Leased Premises, padlocked the entrances and posted guards to
prevent entry and Rosario Textile removed the machinery, equipment, garments and other chattels found
inside the Leased Premises. Consequently, RMC and Peter Pan filed an injunction suit in the trial court
which trial court granted upon posting P50,000 bond by petitioner. RMC filed a motion for the issuance of
a writ of preliminary mandatory injunction for the return of the missing chattels which RTC granted.
Rosario Textile assailed the Order in a special civil action for certiorari with the Court of Appeals. CA
upheld RTC. The SC likewise affirmed the Decision, which attained finality with the entry of judgment on
17 August 1988. On 2 February 1989, the trial court issued an Order requiring Rosario Textile to comply
with the 20 January 1987 and 23 February 1987 Orders and reiterated its orders directing “defendants” to
allow entry to the Leased Premises and to return the various machineries they took. The Sheriff’s Report
stated that copy of the Order was served on Rosario Textile’s counsel in the presence of its Vice-
President for Operations/Personnel, Mr. Antonio Angco. However, Rosario Textile did not comply. In 1993
and 1994, RMC filed two motions to cite Rosario Textile’s board of directors and officers in contempt of
court for refusing to comply with the trial court’s final order. On 8 April 1996, the trial court issued another
Order requiring Rosario Textile (“petitioners’ officers”) to return the sewing machines within 5 days from
notice under pain of contempt. Petitioners’ officers moved for reconsideration, which the trial court denied.
Petitioners filed a Manifestation and Compliance on 7 January 1997 stating that they could no longer
return the sewing machines since these were gutted by the fire. On 23 May 1997, the trial court issued
the Order ruling that the alleged destruction of the sewing machines did not extinguish petitioners’
obligation to return these machines. The trial court held that petitioners were already in default at the time
the fire allegedly destroyed the machines. The dispositive portion of the Order reads: Petitioners assailed
the Orders dated 23 May and 4 December 1997 in a petition for certiorari with the Court of Appeals. The
Court of Appeals dismissed the petition for lack of merit. MR denied. Hence, the instant petition.

CA’s ASSAILED RULING: A violation of a writ of injunction subjects a party to a citation for civil or
criminal contempt, punishable by a fine or imprisonment. Courts may punish for contempt officers and
agents of corporations for breach of an injunction regardless of whether the injunction is directed against
them or the corporation only. The trial court did not deny petitioners’ officers due process even though
they were not impleaded as parties in the main case. Since petitioners violated the writ of injunction
issued for the benefit of a private party, a civil contempt arose, which only requires a quantum of evidence
higher than a mere preponderance. Simply put, the law does not require proof beyond reasonable doubt
in civil contempt.

PETITIONER’S CONTENTION:

They should not be cited for indirect contempt because that the trial court did not give them notice of the
injunction order they supposedly violated; that trial court merely presumed their knowledge of the
injunction order from its receipt by Rosario Textile’s former counsel; in contempt proceedings a court
should observe all the due process requirements attending a criminal proceeding and that proof beyond
reasonable doubt should support a finding of contempt of court.

ISSUE:

Whether or not the order finding petitioners in contempt of court is valid.

HELD: YES.

Officers of the Petitioner Corporation had actual notice of the order. Officers of the petitioner corporation
cannot credibly disclaim knowledge of the order requiring the corporation to return the sewing machines
since petitioners knew or should have known that their personnel took possession of the chattels inside
the private respondent’s factory and transferred them to the petitioners’ warehouse and that the private
respondent demanded the return of the subject machines.The sheriff’s Report dated February 22, 1989
states that the legal counsel for the petitioner corporation and the Vice-President for operations and
personnel were present when he tried to enforce the order of the court against the petitioner but he was
prevented by its security officers. At the very least, the officers of the petitioner corporation had actual
notice of the order. Claim of petitioners’ officers that the trial court did not afford them sufficient notice and
opportunity to be heard in the contempt proceedings is misplaced.

To comply with the procedural requirements of indirect contempt under Rule 71 of the Rules of Court,
there must be (1) a complaint in writing which may either be a motion for contempt filed by a party or an
order issued by the court requiring a person to appear and explain his conduct, and (2) an opportunity for
the person charged to appear and explain his conduct.The trial court complied with these requirements in
this case. When RMC filed motions for contempt, the trial court gave petitioners’ officers an opportunity to
explain their side. Petitioners’ officers filed oppositions to the motions for contempt and even filed motions
to reconsider the orders of the trial court requiring them to return the sewing machines. It is not correct to
say that in contempt proceedings a court should observe all the due process requirements attending a
criminal proceeding and that proof beyond reasonable doubt should support a finding of contempt of court
regardless of whether these are civil or criminal. The Court held in Remman Enterprises, Inc. v. Court of
Appeals that: In general, criminal contempt proceedings should be conducted in accordance with the
principles and rules applicable to criminal cases, in so far as such procedure is consistent with the
summary nature of contempt proceedings. So it has been held that the strict rules that govern criminal
prosecutions apply to a prosecution for criminal contempt, that the accused is to be afforded many of the
protections provided in regular criminal cases, and that proceedings under statutes governing them are to
be strictly construed. However, criminal proceedings are not required to take any particular form so long
as the substantial rights of the accused are preserved. Civil contempt proceedings, on the other hand, are
generally held to be remedial and civil in nature; that is, for the enforcement of some duty, and essentially
a remedy resorted to, to preserve and enforce the rights of a private party to an action and to compel
obedience to a judgment or decree intended to benefit such a party litigant. The rules of procedure
governing criminal contempt proceedings, or criminal prosecutions, ordinarily are inapplicable to civil
contempt proceedings The contempt involved in this case is civil since it arose from petitioners’ act of
defying the trial court’s writ of preliminary injunction, which clearly ordered petitioners’ officers to return all
the sewing machines taken from the Leased Premises.

Burgos v. Macapagal-Arroyo

Facts:

In 2007, Jonas Burgos was abducted at about 1:30 pm by 4 armed men and a woman in civilian clothes
while having lunch at the HapagKainan Restaurant in Ever Gotesco Mall, Quezon City. On the same
year, Jonas’s family files a complaint at the Commission on Human Rights alleging military involvement in
the abduction of Jonas after tracing the license plate number of the vehicle used in the abduction to a
vehicle impounded in the 56th Infantry Battalion of the Armed Forces of the Philippines. The Burgos
family also filed a complaint with the Intelligence Service of the Armed Forces of the Philippines, and
Task Force-USIG National Capital Region. The Burgos family files a petition for writ of habeas corpus in
the Philippine Court of Appeals asking that the government produce Jonas to the court which was denied,
however, by the Armed Forces of the Philippines. Almost five years since the disappearance of Jonas
Burgos, the Burgos family concluded their presentation of witnesses and pieces of evidence for the
Habeas Corpus Petition. The defense shall start presenting their witnesses in May 2012. In light of the
latest developments on the abduction case of Jonas Burgos, the Supreme Court reviews the Court of
Appeal’s decision on the consolidated petitions of Edita Burgos for Habeas Corpus, Contempt and Writ of
Amparo. The assailed CA decision dismissed the petition for the issuance of the Writ of Habeas Corpus
denied the petitioner's motion to declare the respondents in Contempt; and partially granted the privilege
of the Writ of Amparo

Last 2010, the Supreme Court issued a resolution ordering the Commission on Human Rights to continue
the investigation regarding the abduction of Jonas Burgos. The Court tasked the CHR to conduct further
investigations because of the lapses by the PNP-CIDG. In this same Resolution, we also affirmed the
CA's dismissal of the petitions for Contempt and for the issuance of a Writ of Amparo with respect to
President Macapagal-Arroyo, as she is entitled as President to immunity from suit. March 15, 2011 the
Commission on Human Rights submits its report to the Supreme Court. The Commission Submitted the
following findings; A. Based on the facts developed by evidence obtaining in this case, the CHR finds that
the enforced disappearance of Jonas Joseph T. Burgos had transpired; and that his constitutional rights
to life liberty and security were violated by the Government have been fully determined .B. In his
Sinumpaang Salaysay, Jeffrey had a clear recollection of the face of HARRY AGAGEN BALIAGA, JR. as
one of the principal abductors, apart from the faces of the two abductors in the cartographic sketches that
he described to the police, after he was shown by the Team the pictures in the PMA Year Book of Batch
Sanghaya 2000 and group pictures of men taken some year thereafter. The same group of pictures were
shown to detained former 56th IB Army trooper Edmond M. Dag-uman (Dag-uman),who also positively
identified Lt. Harry Baliaga, Jr. Daguman's Sinumpaang Salaysay states that he came to know Lt. Baliaga
as aCompany Commander in the 56th IB while he was still in the military service (with Serial No. 800693,
from 1997 to 2002) also with the 56th IB but under 1Lt. Usmalik Tayaban, the Commander of Bravo
Company C. Most if not all the actual abductors would have been identified had it not been for what is
otherwise called as evidentiary difficulties shamelessly put up by some police and military elites. The
deliberate refusal of TJAG Roa to provide the CHR with the requested documents does not only defy the
Supreme Court directive to the AFP but ipso facto created a disputable presumption that AFP personnel
were responsible for the abduction and that their superiors would be found accountable, if not
responsible, for the crime committed. This observation finds support in the disputable presumption "That
evidence willfully suppressed would be adverse if produced."

(Paragraph (e), Section 3, Rule 131 on Burden of Proof and Presumptions, Revised Rules on Evidence of
the Rules of Court of the Philippines).D. As regards the PNP CIDG, the positive identification of former
56th IB officer Lt. HARRY A. BALIAGA, JR. as one of the principal abductors has effectively crushed the
theory of the CIDG witnesses that the NPAs abducted Jonas. Baliaga's true identity and affiliation with the
military have been established by overwhelming evidence corroborated by detained former Army trooper
Dag-uman.e. Interview with Virgilio Eustaquio, Chairman of the Union Masses for Democracy and Justice
(UMDJ), revealed that the male abductor of Jonas Burgos appearing in the cartographic sketch was
among the raiders who abducted him and four others, identified as Jim Cabauatan, Jose Curament,
Ruben Dionisio and Dennis Ibona otherwise known as ERAP FIVE.

ISSUE:

WON the CHR report on the disappearance of Jonas Burgos is sufficient enough for the SC to issue a
final ruling and to:1) Issue a writ of Habeas corpus.

YES

Declare respondents in contempt

NO

Issue a writ of Amparo

NO

Court’s Ruling AMPARO


1. After reviewing the evidence in the present case, the CA findings and our findings in our June 22, 2010
Resolution heretofore mentioned, including the recent CHR findings that Lt. Harry A. Baliaga, Jr., (

Lt. Baliaga

) of the 56th Infantry Battalion, 7th Infantry Division, Philippine Army is one of the abductors of Jonas, we
resolve to hold in abeyance our ruling on the merits in the

Amparo

aspect of the present case and refer this case back to the CA in order to allow Lt. Baliaga and the present

Amparo

respondents to file their respective Comments on the CHR Report within a non-extendible period of
fifteen (15) days from receipt of this Resolution.2. The Court of Appeals shall continue hearing on
the Amparo petition.3. On the non-compliance of the Office of the Judge Advocate to provide the CHR
with copies of documents relevant to the case of Jonas, and thereby disobeyed our June 22, 2010
Resolution.4. Acting on the CHR's recommendation and based on the above considerations, we resolve
to require General Roa of TJAG, AFP, and the Deputy Chief of Staff for Personnel, JI, AFP,

at the time of our June 22, 2010 Resolution,

and then incumbent Chief of Staff, AFP, to show cause and explain, within a non-extendible period of
fifteen (15) days from receipt of this Resolution, why they should not be held in contempt of this Court for
defying our June 22, 2010 Resolution.

Habeas Corpus

1. In light of the new evidence, the Court hereby dismisses the Court of Appeal’s decision to dismiss the
habeas corpus petit

ion.2. For this purpose, we also order that Lt. Baliaga be impleaded as a party to the

habeas corpus

petition and require him - together with the incumbent Chief of Staff, AFP; the incumbent Commanding
General, Philippine Army; and the Commanding Officer of the 56th IB at the time of the disappearance of
Jonas, Lt. Col. Feliciano - to produce the person of Jonas and to show cause why he should not be
released from detention

Petition of Contempt

1. Two types of Contempt: Criminal contempt is "conduct directed against the authority and dignity of the
court or a judge acting judicially; it is an act obstructing the administration of justice which tends to bring
the court into disrepute or disrespect." On the other hand, civil contempt is the failure to do something
ordered to be done by a court or a judge for the benefit of the opposing party therein and is therefore, an
offense against the party in whose behalf the violated order was made. If the purpose is to punish, then it
is criminal in nature; but if to compensate, then it is civil.2. In proceedings for criminal contempt, the
defendant is presumed innocent and the burden is on the prosecution to prove the charges beyond
reasonable doubt. The presumption of innocence can be overcome only by proof of guilt beyond
reasonable doubt, which means proof to the satisfaction of the court and keeping in mind the presumption
of innocence that precludes every reasonable hypothesis except that for which it is given. It is not
sufficient for the proof to establish a probability, even though strong, that the fact charged is more likely
true than the contrary.

It must establish the truth of the fact to a reasonable certainty and moral certainty a certainty that
convinces and satisfies the reason and conscience of those who are to act upon it.3. For the petitioner
to succeed in her petition to declare the respondents in contempt for filing false returns in the habeas
corpus

Proceedings before the CA, she has the burden of proving beyond reasonable doubt that the respondents
had custody of Jonas.4. In light of the dismissal of the petitions against President Gloria Macapagal
Arroyo who is no the longer the President of the Republic of the Philippines, she should now be dropped
as a party-respondent in these petitions

Negros Oriental II Electric Cooperative vs Sangguniang Panlungsod of Dumaguete

FACTS:

In 1985, the Sangguniang Panlungsod (SP) of Dumaguete sought to conduct an investigation in


connection with pending legislation related to the operations of public utilities. Invited in the hearing were
the heads of NORECO II (Negros Oriental II Electric Cooperative, Inc.) – Paterio Torres and Arturo
Umbac. NORECO II is alleged to have installed inefficient power lines in the said city. Torres and Umbac
refused to appear before the SP and they alleged that the power to investigate, and to order the
improvement of, alleged inefficient power lines to conform to standards is lodged exclusively with the
National Electrification Administration (NEA); and neither the Charter of the City of Dumaguete nor the
[old] Local Government Code (Batas Pambansa Blg. 337) grants the SP such power. The SP averred that
inherent in the legislative functions performed by the respondent SP is the power to conduct
investigations in aid of legislation and with it, the power to punish for contempt in inquiries on matters
within its jurisdiction.

ISSUE: Whether or not LGUs can issue contempt.

HELD: No. There is no express provision either in the 1973 Constitution or in the LGC (BP 337) granting
local legislative bodies, the power to subpoena witnesses and the power to punish non-members for
contempt. Absent a constitutional or legal provision for the exercise of these powers, the only possible
justification for the issuance of a subpoena and for the punishment of non-members for contumacious
behavior would be for said power to be deemed implied in the statutory grant of delegated legislative
power. But, the contempt power and the subpoena power partake of a judicial nature. They cannot be
implied in the grant of legislative power. Neither can they exist as mere incidents of the performance of
legislative functions. To allow local legislative bodies or administrative agencies to exercise these powers
without express statutory basis would run afoul of the doctrine of separation of powers. There being no
provision in the LGC explicitly granting local legislative bodies, the power to issue compulsory process
and the power to punish for contempt, the SP of Dumaguete is devoid of power to punish the petitioners
Torres and Umbac for contempt. The Ad Hoc Committee of said legislative body has even less basis to
claim that it can exercise these powers. Even assuming that the SP and the Ad-Hoc Committee had the
power to issue the subpoena and the order complained of, such issuances would still be void for being
ultra vires. The contempt power (and the subpoena power) if actually possessed, may only be exercised
where the subject matter of the investigation is within the jurisdiction of the legislative body.

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